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`Patent 7,241,034
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`DECLARATION OF DAVID A. SKEELS
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`1, David A. Skeels, declare as follows:
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`1.
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`I make this declaration in support of a motion to be admitted pro hac
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`vice as backup counsel for the patent owner in inter partes review no. IPR2016-
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`00196.
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`2.
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`I am a member in good standing of the State Bar of Texas, the bars of
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`the United States Court of Appeals for the Federal Circuit, and several other federal
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`courts.
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`3.
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`I have never been suspended or disbarred from practice before any court
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`or administrative body.
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`4.
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`I have never had an application for admission to practice before any
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`court or administrative body denied.
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`5.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`6.
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`I have read and agree to comply with the Office Patent Trial Practice
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`Guide and the Board’s Rule of Practice for Trials set forth in part 42 of the Code of
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`Federal Regulations.
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`Case IPR20l6-00196
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`Patent 7,241,034
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`7.
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`I submit to be subject to the PTO’s code of professional responsibility
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`set forth in 37 C.F.R. §§ 10.20 et seq. and disciplinary jurisdiction under 37 C.F.R.
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`§ ll.l9(a).
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`8.
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`I was admitted pro hac vice into PTO proceeding IPR2012-00001 (JL)
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`on December 26, 2012.
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`9.
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`I have an established familiarity with the subj ect matter of this review
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`I as a result of having been lead counsel for the plaintiff in litigations of the patent
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`under review, U.S. Patent No. 7,241,034 B2 (“the ‘034 patent”). Specifically, Ihave
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`been lead counsel for Adaptive Headlamp Technologies, Inc., the owner of the ‘O34
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`patent, in the following cases:
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`(a)
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`v. BMW of North
`Inc.
`Adaptive ‘Headlamp Technologies,
`America, LLC, Civil-Action No.
`l:l4cvO()962, pending in the
`District of Delaware.
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`v. FCA US LLC,
`Inc.
`(b) Adaptive Headlamp Technologies,
`Maserati North America, Inc. & Fiat Chrysler Automobiles N. V ,
`Civil Action No.
`l:l5cv00073, pending in the District of
`Delaware.
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`(c)
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`Adaptive Headlamp Technologies, Inc. v. General Motors LLC,
`Civil Action No. 1:l5cV00781, pending in the District of
`Delaware.
`’
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`12. Hyundai Motor
`Inc.
`(d) Adaptive Headlamp Technologies,
`America, Civil Action No. 1:l5cvO0563, pending in the District
`of Delaware.
`’
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`(e)
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`Adaptive Headlamp Technologies, Inc. v. Mazda Motor ofNorth
`America, Inc., Civil Action No.
`l:l5cvO0782, pending in the
`District of Delaware.
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`
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`Case IPR20l6-00196
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`Patent 7,241,034
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`(f)
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`12. _Mercedes—Benz USA
`Adaptive ‘Headlamp Technologies, Inc.
`LLC, Civil Action No.l:l5cvO0075, pending in the District of
`Delaware.
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`(g) Adaptive Headlamp Technologies, Inc. v. Nissan North America
`Inc, Civil Action No. l:l5cvO0074, pending in the District of
`Delaware.
`‘
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`Toyota Motor Sales,
`(h) Adaptive Headlamp Technologies, Inc.
`U.S.A., Inc., Civil Action No.
`l:l5cv00779, pending in the
`District of Delaware; and
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`(i)
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`12. Volvo Cars of North
`Adaptive Headlamp Technologies, Inc.
`America, LLC, Civil Action No. l:l5cv00780, pending in the
`District of Delaware.
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`My experience in these cases has provided me with a knowledge of the ‘O34
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`patent, the prior art cited in the petition, and the patentability issues in this review.
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`I declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true, and further
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`that these statements are made with the knowledge that willful false statement and
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`the like so made are punishable by fine or imprisonment, or both under Section 1001
`ofthe Title 18 ofthe United States Code, and that such willful false statements may
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`jeopardize the validity or enforceability of the ‘034 patent.
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`Date:
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`I?/[4//( B
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`David A. Skeels